Airlines for America (A4A), the industry trade organization for the leading U.S. airlines, today urged the Federal Aviation Administration (FAA) to significantly revise its proposed requirements for pilot certification and provide a system that builds on the industry’s strong safety record, is recommended by safety experts and that recognizes the quality of a pilot’s training and experience, rather than relying solely on a specific quantity of flight hours.

“Hard-hour minimum requirements are not a substitute for the quality of a pilot’s training and experience,” A4A said in its comments filed with the FAA, noting that the change as proposed by the FAA would have unintended consequences. “Failure to provide additional options for meeting the requirements, as recommended by safety experts, will result in an unnecessary pilot shortage and significant barriers to recruiting regional and mainline pilots.”

A4A comments are in response to the FAA Notice of Proposed Rulemaking issued on Feb. 29, 2012, which would require that first officers hold an Airline Transport Pilot (ATP) certificate and a minimum of 1,500 hours flight time to obtain the certificate. Existing FAA regulations do not require a first officer to hold an ATP certificate; only the pilot in command must meet this certificate requirement.

As part of its recommend revisions to the proposal, A4A recommends that the FAA establish a restricted ATP certificate for Second in Command pilots, which takes experience and training into account. A4A also recommends that the FAA form an Aviation Rulemaking Committee to provide recommendations on the adoption of a Multicrew Pilot Licensing Program, which are used throughout the world by other safety regulators and take into account the realities of current operations and training.